defence pfas construction and maintenance …€¦ · the commonwealth work health and safety...
TRANSCRIPT
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Guidance for managing the risks of PFAS contamination for works on the Defence estate
INFRASTRUCTURE DIVISION
PFAS INVESTIGATION AND
MANAGEMENT BRANCH
Version 2.1
July 2019
BS1062257
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 I
Change History
Version Date Description Approval
1.0 12/03/2018 Published Luke McLeod
2.0 June 2019 Internal Release Luke McLeod
2.1 July 2019 Public Release Luke McLeod
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 II
KEY MESSAGES
Objective
To support decision-makers in managing risks from PFAS contaminated soil, water and demolition
waste in the context of construction and maintenance works on the Defence estate.
Application
This document applies to construction and maintenance works on the Defence estate where there
is evidence of potential for PFAS contamination.
This document does not apply to PFAS contaminated site investigations.
This document does not provide specific guidance for managing very small volumes of displaced
soils or water (in aggregate for the works, approximately <10 m3 soil or <1000 L water) where it is
reinstated within the works site. Standard operating procedures apply.
This document only applies to construction and demolition waste where associated with AFFF
infrastructure or where there is reason to believe that the material has been in direct contact with
AFFF concentrate. In all other cases, manage construction and demolition waste using
appropriate demolition waste standards and procedures in accordance with relevant Defence,
State and Territory requirements.
This document does not address WHS requirements. The Commonwealth Work Health and Safety
Regulations (2011) apply to the management of PFAS contamination on the Defence estate.
PFAS sampling and analysis
Significant testing has already occurred across much of the Estate. First look for available PFAS
data before sampling. Start with GEMS, then check the Defence PFAS webpage. If PFAS
investigations are ongoing, contact Defence PFASIM Branch. All additional sampling should be
fully justified as filling critical data gaps.
Standard laboratory analysis LOR should be used. These are currently 0.005 mg/kg for soil and
sediment, and 0.01 µg/L for water.
TOPA and trace analysis should not take place unless fully justified or required by the regulator.
PFAS contaminated materials
When managing PFAS contaminated waste materials, apply the waste management hierarchy to
achieve the optimal least cost and compliant solution: avoid – reuse – (reprocess / recycle /
energy recovery) – dispose. Refer to the DEQMS Waste Minimisation website for more
information.
Refer to the work objectives and apply this framework using all available data to inform
professional judgement and undertake an assessment of risk for the reuse of material.
PFAS Investigation and Management Branch program
PFASIM Branch is currently delivering a range of services for the investigation, assessment and
management of PFAS contamination across the Defence Estate.
Where PFAS Management Area Plans (PMAPs) are available, PFASIM Branch should be
contacted prior to the commencement of work planning to ensure alignment and integration of the
management actions identified within the PMAP and the works delivered on the Base.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 III
Contents
KEY MESSAGES ............................................................................................................................................................... II
1 INTRODUCTION ........................................................................................................................................................ 1
1.1 About this document ..................................................................................................................................... 1
1.1.1 Purpose ........................................................................................................................................... 1
1.1.2 Goals ............................................................................................................................................... 1
1.2 Application .................................................................................................................................................... 1
1.2.1 Who will use this framework? .......................................................................................................... 1
1.2.2 When to use this framework ............................................................................................................ 2
1.2.3 Other compliance requirements ...................................................................................................... 2
1.3 Background................................................................................................................................................... 3
1.4 What’s different about PFAS contamination? ............................................................................................... 3
1.4.1 The nature of PFAS ........................................................................................................................ 3
1.4.2 New knowledge and new remediation techniques .......................................................................... 4
1.5 PFAS on the Defence estate ........................................................................................................................ 4
1.6 PFAS contamination risks for works on the Defence estate ......................................................................... 4
1.7 Trigger levels used in this framework ........................................................................................................... 5
1.7.1 Source references ........................................................................................................................... 5
1.7.2 Relationship with other Defence environmental management guidance ......................................... 5
1.8 Integrating and aligning PFAS management across the estate .................................................................... 5
2 HOW TO USE THE GUIDANCE IN THIS FRAMEWORK ......................................................................................... 7
2.1 Check for updates ......................................................................................................................................... 7
2.2 Is the Base currently being investigated or managed by PFASIM Branch for PFAS contamination? ........... 7
2.3 Roles and responsibilities ............................................................................................................................. 7
2.4 Work, health and safety ................................................................................................................................ 8
2.5 Sampling data, recording and reporting ........................................................................................................ 9
2.5.1 Sampling data ................................................................................................................................. 9
2.5.2 Defence Contaminated Sites Records .......................................................................................... 10
2.5.3 Environmental Data Management Software (ESdat) Database .................................................... 10
2.6 Risk management principles for PFAS contamination ................................................................................ 10
2.6.1 Assessment of risk – reuse ........................................................................................................... 11
2.6.2 Role of remediation in the Framework .......................................................................................... 12
2.6.3 Adaptation to local conditions ........................................................................................................ 12
2.7 Expert advice .............................................................................................................................................. 13
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 IV
3 SOIL ......................................................................................................................................................................... 15
3.1 Planning for risk management of PFAS contamination in soil .................................................................... 15
3.1.1 Consulting with other Defence decision-makers ........................................................................... 15
3.1.2 Soil sampling ................................................................................................................................. 15
3.1.3 Managing very small volumes of contaminated soil ...................................................................... 15
3.1.4 Management of sludge and slurry ................................................................................................. 16
3.2 Soil waste management hierarchy .............................................................................................................. 16
3.2.1 On-works site management .......................................................................................................... 16
3.2.2 Off-works site, on-Base management ........................................................................................... 17
3.2.3 Off-Base management .................................................................................................................. 17
3.2.4 Storage on-Base ........................................................................................................................... 17
3.3 Reuse in high-sensitivity areas ................................................................................................................... 17
3.4 Soil sampling and characterisation ............................................................................................................. 18
3.4.1 Approaches to Sampling ............................................................................................................... 18
3.4.2 Soil sampling - disposal off Base .................................................................................................. 19
3.4.3 Soil sampling - reuse on Base ....................................................................................................... 19
3.5 Soil categorisation ...................................................................................................................................... 19
3.6 Soil management actions ........................................................................................................................... 20
3.6.1 Category 1 soil management ........................................................................................................ 20
3.6.2 Category 2 soil management ........................................................................................................ 20
3.6.3 Category 3 soil management ........................................................................................................ 21
3.6.4 Category 4 soil management ........................................................................................................ 22
4 WATER .................................................................................................................................................................... 23
4.1 Planning for risk management of PFAS contamination in water ................................................................. 23
4.1.1 Water management principles ....................................................................................................... 23
4.1.2 Prevention of stormwater contamination ....................................................................................... 24
4.1.3 Managing very small volumes of contaminated water ................................................................... 24
4.2 Sampling and analysis ................................................................................................................................ 24
4.2.1 Project coordination ...................................................................................................................... 24
4.2.2 Other PFAS compounds ............................................................................................................... 25
4.3 Water management .................................................................................................................................... 25
4.3.1 Irrigation and Infiltration ................................................................................................................. 26
4.3.2 Discharge via creeks or stormwater drains ................................................................................... 26
5 CONSTRUCTION AND DEMOLITION WASTE ...................................................................................................... 29
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 V
5.1 Construction and Demolition waste – management principles ................................................................... 29
5.2 Lessons from previous investigations ......................................................................................................... 29
5.3 Whether to conduct sampling of C&D waste .............................................................................................. 30
5.3.1 Sampling requirements ................................................................................................................. 30
5.3.2 Disposal to commercial landfill ...................................................................................................... 30
5.4 Reuse of C&D waste .................................................................................................................................. 31
APPENDIX A: GLOSSARY .............................................................................................................................................. 33
APPENDIX B: STANDARD LABORATORY SUITE ........................................................................................................ 36
APPENDIX C: STOCKPILING REQUIREMENTS ............................................................................................................ 38
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 1
1 INTRODUCTION
1.1 About this document
1.1.1 Purpose
The Defence PFAS Construction and Maintenance Framework has been developed to support decision
makers in managing risks from material contaminated with per- and poly- fluoroalkyl substances (PFAS) in
the context of construction and maintenance works on the Defence estate.
Specifically, guidance is provided on the management of PFAS contamination for:
soil;
water; and
construction and demolition waste.
The framework is not to be used for targeted PFAS investigations or managing wastes generated through
pollution incidents, instead refer to the Department of Defence Pollution Prevention Management Manual,
2017.
1.1.2 Goals
The goals of this guidance are:
to provide options for the management of PFAS contaminated soil, water, construction demolition
waste and other materials, that will mitigate the risks associated with PFAS contamination at the
works site, on the Base, or in the vicinity of the Base;
to guide decision-making for efficient and compliant solutions when managing PFAS contaminated
materials in this context;
to minimise the impact of risk-management of PFAS contamination on Defence capability;
to ensure an integrated approach to PFAS risk management aligned with the PFAS Management
Area Plans (PMAPs), any interim actions to manage potential risks, and works requirements; and
to provide guidance that is consistent with the PFAS National Environmental Management Plan
(PFAS NEMP).
1.2 Application
1.2.1 Who will use this framework?
This framework applies to:
all Defence delivered infrastructure works:
- Defence (including contractors) carrying out public works,
including construction and maintenance works on the Defence
estate; and
- Defence Environmental staff responsible for environmental
approvals associated with relevant works.
The Framework must be provided as a compliance requirement for all managers, developers and deliverers
of such works.
What does that word mean?
Appendix A contains a glossary
of words and acronyms.
In this document, the word
‘Base’ means the Defence
property on which the works site
is located. This is whether or not
the Defence property is a
designated ‘Base’.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 2
This framework should be used during the scoping, development and delivery phases of projects, including
Scope and Masterplan Feasibility Reports, by Site Selection Boards, in Design Reviews and in the Project
Review and Assessment Process (PRAP).
See section 2.3 for a listing of roles and responsibilities.
1.2.2 When to use this framework
This framework applies to all Bases and other properties in the Defence estate.
Particular consideration should be given to works that may occur at properties:
identified online at the Defence PFAS Investigation and Management Program website;
listed on the Defence Garrison Estate Management System (GEMS) as having PFAS contamination;
where previous environmental testing has identified PFAS contamination; or
where there is known history of the use and/or storage of Class B fire-fighting foam (or an incident
where the foam was used) at or nearby the works site or a proposed reuse site.
The framework does not apply:
to targeted PFAS contaminated land investigations, including for investigation derived waste (IDW);
to works occurring in an area on Base where there is no evidence of actual or likely presence of
PFAS contamination;
where the total volume of soil being displaced at a works site is below 10 cubic metres and it is
being reinstated back within the works site;
where the volume of water being displaced from the environment is below 1000 litres and the water
is returned to ground for infiltration within the works site within 48 hours; and
to construction and demolition waste except where it is associated with Class B aqueous film
forming foam (AFFF)) infrastructure (e.g. training, storage or deluge systems) or where there is
reason to believe that the material has been in direct contact with AFFF (incident response or other
release).
1.2.3 Other compliance requirements
The guidance in this framework should be applied in conjunction with:
any existing property approvals or ECCs;
site management or BM, ADES, ESM, ESO requirements on Base;
State or Territory environmental regulations;
Work Health and Safety Act 2011 (Commonwealth);
Work Health and Safety Regulations 2011 (Commonwealth);
consideration of any other co-contaminants identified at the works site;
Defence guidance set out in section 1.7.2 as applicable; and
PFAS Management Area Plan (see section 1.8) and PFASIM Branch guidance on applicable Interim
Response Management Actions relating to the property.
PFAS National Environmental Management Plan (HEPA)
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 3
1.3 Background
PFAS are a group of anthropogenic compounds which include perfluorooctane sulfonate (PFOS),
perfluorohexane sulfonate (PFHxS), and perfluorooctanoic acid (PFOA). PFAS have been widely used
around the world since the 1950s to make products that resist heat, stains, grease and water. These
products include hydraulic fluid, stain resistant applications for furniture and carpets, packaged food
containers, waterproof clothing, personal care products and cleaning products.
Due to their effectiveness in extinguishing liquid fuel fires, PFAS are an ingredient in AFFF used extensively
worldwide by both civilian and military authorities from about the 1970s. Legacy formulations of AFFF
contained long chain1 PFAS, specifically PFOS and PFOA, as active ingredients that are now known to be
persistent in the environment and in humans. PFHxS is also commonly found in the legacy firefighting foam
as an impurity in the manufacturing process.
PFOS is listed in Schedule 7 of the Poisons Standard (the SUSMP); and in the Safe Work Australia’s
Hazardous Chemical Information System. Most people living in developed nations will have some level of
PFAS in their bodies due to their widespread use. In June 2016, the Environmental Health Standing
Committee (enHealth)2, published guidance statements advising that there is currently no consistent
evidence that exposure to PFOS and PFOA causes adverse human health effects3. However, since these
chemicals remain in humans and the environment for many years, it is recommended that as a precaution,
human exposure to PFAS be minimised.
PFOS was listed in 2009 under the Stockholm Convention on Persistent Organic Pollutants (POPs), with
PFOA listed in 2019 and PFHxS currently under consideration for listing. These chemicals are considered to
be highly persistent, can bioaccumulate and bioconcentrate, and are toxic to some aquatic organisms. PFAS
are also highly mobile, particularly in aquatic environments, with limited containment and remediation
options.
1.4 What’s different about PFAS contamination?
1.4.1 The nature of PFAS
PFAS has many qualities that combine to present particular challenges in locating, containing and
remediating PFAS contamination.
Water is the primary method of PFAS contamination transferring from a source to a receptor, such
as a person, animal, plant, eco-system, property or a water body;
PFAS is reasonably soluble in water and can rapidly leach through soils or disperse in waterways,
travelling long distances;
PFAS can permeate some solid surfaces. This includes concrete and other porous building
materials, such as some firefighting appliances and apparatus, storage tanks and fire training pads;
PFAS are very chemically and biologically stable and have a low vapour pressure, so they are
resistant to breakdown and evaporation; and
1 PFAS with longer carbon chain structures are considered more hazardous
2 enHealth is a subcommittee of the Australian Health Protection Principal Committee, and is responsible for providing agreed environmental health policy advice. Its membership includes representatives from the Health portfolios of Australian and New Zealand governments.
3 enHealth Guidance Statements on per- and poly-fluoroalkyl substances (2017)
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 4
Some PFAS (including PFOS, PFHxS and PFOA) are environmentally persistent and
bioaccumulative. This means that some plants and animals may take up PFAS through soil and
water. It may then bioaccumulate and become a part of the food chain.
1.4.2 New knowledge and new remediation techniques
Developments in analytical methods have improved detection of PFAS over the past six years, but there are
still levels below which PFAS cannot be accurately quantified, although it may be present (known as the ‘limit
of reporting’ or ‘LOR’).
As an emerging contaminant, the understanding of the behaviour and impacts of PFAS contamination on
human health and the environment is still developing, such as what concentrations of contamination in water
and soil give rise to concern, and when. In some cases, site-specific risk management measures may need
to be developed to minimise human exposures and protect the environment.
Remediation technologies are at various stages of research and development. They are currently more
advanced in the treatment of water than for soil. Advice on the latest technology can be provided by PFASIM
Branch.
The science of PFAS impacts and technologies for managing PFAS is constantly evolving. As a result, this
framework may be updated to meet changing national standards.
1.5 PFAS on the Defence estate
The majority of PFAS contamination on the Defence estate is the result of the historic use and storage of
legacy firefighting foams, specifically Class B aqueous film forming foams (AFFF). These foams have been
used for training purposes or incident control. In the Defence context, sources and reservoirs of PFAS
contamination are generally associated with current or former fire training areas, accident scenes where
AFFF was used, AFFF product storage areas, fire stations or areas where fire suppression systems were
used.
From 2004, Defence commenced phasing out its use of legacy firefighting foams containing PFOS and
PFOA as active ingredients. Defence now uses a firefighting product called Ansulite. Ansulite does not
contain PFOS and PFOA as active ingredients, only in trace amounts. Defence policy in relation to the way it
uses and stores AFFF has been reviewed and updated.
The Defence National PFAS Investigation and Management Program is progressing at Defence properties
across Australia as a result of the historical use and storage of legacy AFFF. For those sites that have
concluded the investigations phase, Defence is preparing PFAS Management Area Plans, high level plans
for managing elevated exposure risks identified as part of the site specific human health or ecological risk
assessments.
Defence has undertaken an iterative, evidence based approach to efficiently prioritise and investigate sites
across the estate most likely to be significantly contaminated or that may potentially pose a risk to human
health and the environment. All other properties will be subject to routine contaminated site investigations,
with PFAS considered as a contaminant of potential concern. Further work to address those areas with
identified contamination will be considered for remediation and management actions. This information should
be considered during all phases of project management for construction and remediation works.
1.6 PFAS contamination risks for works on the Defence estate
The risks associated with PFAS contamination in the context of works on the Defence estate arise because:
PFAS contamination may be found in soils, water (e.g. groundwater, surface water), or construction
and demolition waste;
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 5
works can mobilise existing contamination through demolition, excavation, changed storm water
flows, changes to groundwater flows, large-scale dewatering, dust suppression or stockpiling; and
once mobilised, PFAS can rapidly leach through soils or disperse in drainage channels, shallow
groundwater and surface waterways where they may impact on human health and the environment.
1.7 Trigger levels used in this framework
This framework is based on appropriate risk management of PFAS contaminated material on Defence
properties undergoing construction and maintenance works where the nature and extent of required
management actions for PFAS contamination are not yet known. Where the investigation process for a
Defence property has been completed, a PMAP will be published on the Defence PFAS webpage that
describes the remediation works warranted at the property. In these cases guidance in the PMAP may
supersede this document (see section 18).
The trigger levels provided in this document are not intended to be used for remediation targets, health-
based criteria or for regulatory purposes.
The need for management of contaminated materials (e.g. remediation or reuse) is triggered by an
exceedance of trigger values stated in this framework, based on a site-specific assessment. The values
should be used in conjunction with relevant, up to date guidance documents (see section 1.7.1).
The trigger levels specified in this framework apply to PFOS, PFOA and PFHxS, as human health guidance
values are available for these PFAS in Australia. Some ecological guidance values are available for PFOS
and PFOA. As with other components of this framework, guidance values may be expected to be updated as
the science, policy and remediation technologies are developed.
1.7.1 Source references
In deriving PFAS trigger levels for management of soils, the following guidance was referenced:
PFAS National Environmental Management Plan (NEMP), (HEPA 2018) – currently being updated.
National Environment Protection (Assessment of Site Contamination) Measure 1999, Schedule B1,
as amended in 2013 (NEPM 2013).
Final Health Based Guidance Values (HBGV) for PFAS for use in site investigations in Australia,
FSANZ February 2017 (FSANZ 2017).
1.7.2 Relationship with other Defence environmental management guidance
Defence environmental management guidance includes, but is not limited to:
Department of Defence Contamination Management Manual (DCMM), 2018.
Department of Defence, Infrastructure Division, Environment and Engineering Branch, Pollution
Prevention Management Manual, 2017.
Department of Defence, Defence Estate Water Policy.
Department of Defence, Defence Estate Water Strategy 2014-2019.
1.8 Integrating and aligning PFAS management across the estate
Since PFAS investigations commenced under the Defence National PFAS Investigation and Management
Program, Defence has sought to develop a comprehensive evidence-based approach to managing the risks
associated with PFAS contamination. This has resulted in a two-stage approach:
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 6
1 Interim Response
Management (IRM) Actions
During the investigation phase, some risks are identified that require the
commencement of management actions before the conclusion of
investigations. Providing drinking water to people whose drinking supply is
contaminated by PFAS is an example. Other actions may also be
commenced on some Bases to address off-Base migration or treatment of
contaminated groundwater.
2 PFAS Management Area
Plan (PMAP)
A PMAP sets out a comprehensive plan for Defence to manage the elevated
risks of PFAS contamination as identified in a completed DSI report and any
risk assessment reports, on and from a Defence property. Any IRM actions
underway are assessed for efficiency and effectiveness and incorporated as
relevant into the PMAP.
This means that for some sites, works and either IRM actions or PMAP actions may take place on
overlapping or nearby areas. It is important for the works team to liaise with PFASIM Branch to deliver
integrated PFAS risk management actions that take advantage of opportunities to align timing and
expenditure.
A PMAP is a living document reviewed on an annual basis. This allows changes in circumstances to be
taken into account, including regulatory guidance on remediation criteria, the availability of new technologies
and the results of an ongoing monitoring plan that informs changes in the behaviour of a contamination
plume, evidences progress in risk management or the effectiveness of specific response actions.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 7
2 HOW TO USE THE GUIDANCE IN THIS FRAMEWORK
2.1 Check for updates
Risk management of PFAS contamination is rapidly evolving. To ensure the most recent version of this
guidance is being used, check the publication on the DEQMS website.
A PFAS National Environmental Management Plan (NEMP) has been published by the Heads of EPAs
Australia and New Zealand (HEPA) (including State and Territory environmental regulators and the
Commonwealth Department of Environment and Energy) to guide the management of PFAS across
Australia. An updated version of the PFAS NEMP was released for public consultation in March 2019. Any
relevant requirements will be reflected in an addendum or updated version of this Framework.
2.2 Is the Base currently being investigated or managed by PFASIM Branch for PFAS contamination?
Properties that are currently being investigated or managed by PFASIM Branch are listed online at Defence
PFAS Investigation and Management Program website. Where the works site is on a Defence property being
investigated or managed by PFASIM Branch, this means:
sampling data, detailed site investigation (DSI) reports and/or risk assessment reports (HHERA,
HHRA, ERA) are likely to be available for the Base; and
works should be aligned with any management actions (remediation, containment, stockpiling) that
may be planned by PFASIM Branch. This has the potential to save time and money for both the
project/works and for PFASIM Branch.
For properties where PFAS investigations are complete, DSI and risk assessment reports are publicly
accessible from the above website.
2.3 Roles and responsibilities
The following roles and responsibilities apply in connection with implementation of this framework.
Table 1 Roles and responsibilities
Roles PFAS Management Responsibilities
Base Manager (BM) Coordinates the provision of Base services.
Capital Facilities Infrastructure
(CFI)
Delivers Defence construction projects. Ensures this Framework is being
adopted and implemented for projects.
Commonwealth Department of
the Environment and Energy
PFAS IGA, EPBC Act referrals and approvals, PFAS NEMP coordination, ASC
NEPM.
Program owner for the Sustainable Access to Drinking Water Program.
Environment and Engineering
Branch
Defence Subject Matter Experts and policy owner for environment, engineering,
heritage, contamination management, pollution prevention, energy, water and
waste management within Defence.
Approves project specific documentation.
Environmental/Lead
Consultant
Contracted by Defence or on behalf of Defence to undertake environmental
testing, provide technical advice (including site auditing) or develop
proposals/plans/certificates.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 8
Estate Maintenance and
Operations Services (EMOS)
Provides maintenance and operations support services to the Defence Estate.
Provides delivery of selected maintenance projects and Project Support Services
through the Estate Works Program.
Holds pertinent project and contract documentation including environmental and
waste disposal documentation.
Main/Lead/Principal/Head
Contractor
Contracted to Defence to undertake construction and maintenance works on the
Defence estate.
National Program Services
(NPS)
Contracted to Defence to provide programming and management of the Estate
Works Program.
PFAS Investigations
Management (PFASIM)
Branch
Provision of PFAS policy advice within Defence.
Coordinate resolution of enquires within PFASIM Branch.
Develop & promote PFAS guidance and management resources to CFI & SDD
stakeholders.
Project management of PFAS environmental investigations and response
management actions.
Provision of Defence and whole of government PFAS related policies.
Project Delivery Services
(PDS)
Contracted to Defence to provide project/contract management of maintenance
projects (Estate Works Program).
Holds pertinent project and contract documentation including environmental and
waste disposal documentation.
Project Manager/Contract
Administrator (PMCA)
Contracted to Defence to provide project/contract management oversight of
construction projects (program is part of the contract, such as meeting
milestones).
Holds pertinent project and contract documentation including environmental and
waste disposal documentation.
SDD Environment and
Sustainability team including
ADES, ESM, ESO
Lead stakeholder when considering reuse of PFAS impacted materials – direct
link to SMEs.
Oversight of environmental and heritage issues for a specified base/s.
Review Construction Environmental Management Plan.
Approve Environmental Clearance Certificates & Remediation Action Plans.
Service Delivery Division and
its contractors (SDD)
Provides essential on-the-ground services and support to Defence personnel
around Australia through the Base Services Contract (BSC).
State/Territory environmental
regulator
Approve licences for transportation of waste and storage/disposal of waste at
licenced waste disposal facilities.
Consultation or inform on remediation activities within State/Territory
jurisdictions.
2.4 Work, health and safety
All works undertaken on the Defence estate must comply with requirements in the Work Health and Safety
Act (Cth) 2011 (WHS Act), the Work Health and Safety Regulations (Cth) 2011 and the Defence Work Health
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 9
and Safety (WHS) Manual. The Commonwealth Regulator is Comcare. For construction and maintenance
works on Bases that have completed a PFAS risk assessment, management measures may have been
identified to mitigate any risks to human health.
The Defence WHS manual provides safety policy and procedures with electronic links to corporate tools,
services and expert advice to address the management of activities where people are exposed to hazards,
as required by the WHS legislation as it applies to Defence.
In general, absorption of PFAS due to dermal exposure is considered to be negligible in comparison to the
ingestion pathway. Additionally, PFAS compounds of primary concern are not sufficiently volatile, and thus
exposure via inhalation is also not considered to be significant. The environmental concentrations typically
detected on Defence sites are low and are unlikely to pose WHS risks in a typical construction scenario.
Therefore additional workplace precautions or PPE are not required beyond compliance with standard Work
Health and Safety procedures4 for construction.
Water quality monitoring must be undertaken in accordance with the WHS requirements of the
EMOS/PDS/NPS contractor which are aligned with Defence WHS requirements. For demolition works,
standard WHS requirements should also be adopted. Similarly, WHS PFAS exposure risks within the
identified Management Area are not within the scope of the PMAP. They are appropriately managed by the
relevant contractor in accordance with applicable work, health and safety legislation.
2.5 Sampling data, recording and reporting
2.5.1 Sampling data
Data for the works site and other parts of the Base may be available as a result of previous investigations.
Check the following:
Defence PFAS webpage for published PSI reports, DSI reports, PMAPs and risk assessments;
GEMS EFM – CSR (the former Contaminated Sites Register) for records of PFAS contamination on
the project/works site (see section 2.5.2);
ESdat Database (see section 2.5.3);
PFASIM Branch for information on investigations not yet concluded; and
ADES/ESM/ESO for the site/base for information on investigations not yet concluded or other
planned and current works programs
Where this information is available, use or supplement it (as required) with site-specific sampling to provide
sufficient information on which to base decisions under this Framework.
Potential contamination must be considered early in the design stage to help identify options for soil and
water management and allocation of resources. In some cases, early planning can identify suitable reuse
options for PFAS contaminated materials, or identify changes in design to minimise spoil that would
otherwise be generated. For example, off-Base transport and disposal of contaminated material must comply
with regulatory requirements of the relevant State/Territory. National hazardous waste coding (e.g. M270),
may be required. There may also be a requirement for sampling other potential contaminants of concern
4 Reference Safe Work Australia for further information on Hazardous Chemical Information Systems (HCIS) http://hcis.safeworkaustralia.gov.au/ and safety data sheets https://www.safeworkaustralia.gov.au/sds
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 10
based on a review of site history, and in particular, additional analyses will be required if material is to be
disposed of offsite.
Defence has tolerance to accept a certain level of risk and uncertainty to meet its objectives for each project
or program. Risks associated with managing PFAS contamination should be balanced with other project
risks. Evidence-based decision making, through use of available data and site specific information, will help
optimise the risk management.
Avoid oversampling and over-testing by careful planning, consultation and assessment of current data, site
characteristics and whether material is intended for reuse on Base, stockpiling (generally a temporary
measure) or disposal. When scoping projects/works during the procurement phase, ensure that the level of
sampling and testing for PFAS contamination is fully justified and conforms to the requirements of this
Framework.
Consultation on the appropriate level and type of sampling for works is available:
directly between the Base (ADES/ESM/ESO) and contractors;
with EMOS contractors;
with SMEs during project procurement, planning and delivery;
during the Design Review and/or Project Review and Assessment Process;
from Site Selection Boards; or
directly from PFASIM Branch.
2.5.2 Defence Contaminated Sites Records
Contamination on the Defence properties was previously recorded in the Contaminated Sites Register. This
is now the Garrison Estate Management System, Environmental Factor Management - Contaminated Sites
Records (GEMS EFM-CSR). Contamination on the works site is to be registered in GEMS EFM-CSR. For
further information please refer to the Defence Contamination Management Manual.
2.5.3 Environmental Data Management Software (ESdat) Database
Environmental Data Management Software (ESdat) is a specialist environmental database system used to
compile a broad spectrum of environmental data and produce results tables, graphs, maps and reports.
ESdat should be used to compile laboratory analytical results for all environmental samples including PFAS
and other contaminants, in accordance with the Defence Contamination Management Manual (Annex L). As
the database increases in size, consultants/contractors will also be able to access datasets of PFAS
environmental testing to inform desktop analysis. Consultants and contractors should contact the
Environment and Engineering Branch ([email protected]) and PFASIM Branch
([email protected]) to discuss access to ESdat data. Refer to the Defence
Contamination Management Manual, Annex L for the naming conventions for surface water, ground water,
soil and sediment.
2.6 Risk management principles for PFAS contamination
The following risk management principles apply to this guidance.
Under this framework, management actions include:
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 11
On-work site management;
Off-work site, on-Base management; and
Off-Base management.
The following preference hierarchy applies to options for PFAS contamination management:
On-work site management of the contamination so that the risks are reduced to an acceptable level.
Where work site management is not practicable, other locations on Base for the beneficial re-use of
the material may be considered so that the risks are reduced to an acceptable level and other risks
are not created.
Where on-Base management is not appropriate, off-Base management of the contamination in order
that the risks are reduced to an acceptable level may be required.
A PFAS management action:
may only be pursued where the predicted impact of the action does not increase the risk or lead to
unacceptable risk of PFAS contamination affecting human health or the environment;
should be proportionate to risks (see section 2.6);
should seek to conform and align with the actions identified within site-specific PMAPs;
should be adapted for local conditions;
should be efficient and must be compliant; and
should apply the Defence Risk Management Framework, (includes operational considerations).
Source / Pathway / Receptor: categories of risk management for contamination
A risk may occur when a source of contamination (such as soil contaminated with PFAS) is linked to a sensitive
receptor (such as a person or matter of national environmental significant [MNES]) via an exposure pathway (such as
stormwater flow to a local water supply).
Response to a risk may involve one or more of the following three principal components:
source management by removal, destruction, treatment, disposal and/or other methods leading to the
source no longer being present.
pathway management by capping, containing, stabilisation, diversion, point of use treatment and/or other
methods where the source remains in place but pathways are managed.
receptor management by relocation, institutional controls, behaviour management and/or other methods
focussed on the receptor.
Figure 1 contains a schematic diagram of contamination sources, pathways and receptors, known as a Conceptual
Site Model (CSM).
2.6.1 Assessment of risk – reuse
When assessing whether to reuse PFAS contaminated materials generated on a Base, it is critical to:
consider the levels of contamination of the materials (see Chapters 3, 4 and 5), and
consider the characteristics of the reuse site, in particular:
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 12
- site drainage: Where does surface water flow or accumulate? Where do stormwater channels
drain? In which direction does any groundwater flow?
- proximity to the Defence property boundary: What is the risk of any contaminated water
resulting from the reuse migrating from the Defence site?
consider the risks for sensitive receptors, including direct and indirect receptors.
consult with the ADES, ESM, BM.
In many cases, the works team will already be aware of Base boundaries and drainage networks. In other
cases, this information may already be available in the form of a conceptual site model (CSM). A CSM is a
description or image of the characteristics and processes at a site that impact on how contamination at the
site can move or change, and where it can end up, such as in drinking water or seafood.
Check GEMS EFM-CSR in the first instance. If the site has been the subject of a PFAS DSI, the CSM will be
available in the DSI report on the Defence PFAS webpage. Related health and ecological assessments may
also provide useful information.
Depending on the complexity of the site, an assessment may be required by the works team or by an
experienced environmental consultant.
2.6.2 Role of remediation in the Framework
The extent to which remediation will be required for any specific area of identified PFAS contamination on
specific Bases is in the process of being determined for many Defence properties and is dependent on the
development of the corresponding PFAS PMAPs. Remediation criteria and available technologies for PFAS
are still evolving so approaches to remediation may also change over time.
Where remediation of areas of elevated PFAS contamination can be efficiently implemented as part of
infrastructure works, planning and development of any remediation options should be undertaken in
consultation with PFASIM Branch.
2.6.3 Adaptation to local conditions
Management options addressed within the framework should be site-specific and consider local conditions.
These may include:
Environment and land-use characteristics
- Local weather, hydrological and soil characteristics.
- Presence of sensitive receptors that may reasonably be affected by the contamination.
Technological and financial parameters
- Availability of best-practice management systems, treatments and technologies.
- Availability of treatment/storage management options to manage waste streams.
- Degree of confidence in available treatment techniques.
- Longevity and sustainability of the solution.
- Need for ongoing operations, management, maintenance or monitoring.
- Cost-efficiency.
Impacts of proposed action
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 13
- Potential for cross-contamination (new contamination resulting from the action), and
remobilisation (actions that may trigger movement of PFAS, usually from a previously stable
condition).
- Evaluation of proposed reuse sites that may create new potential pathways to human health or
sensitive environmental receptors (additional management options that prevent or mitigate new
pathways may be required).
- Potential human exposure based on land use.
- Potential impacts on environmental values, both on- and off-Base, such as surface water and
groundwater quality, aquatic species, and matters of national environmental significance.
- Community impacts (including the impact of any truck movements associated with off-Base
management, through the local community and on local infrastructure).
- Consideration or guidance by the jurisdictional regulator, where relevant.
- Conflicting redevelopment projects and their footprints.
2.7 Expert advice
If environmental consultants have been engaged for a project, they may be able to use their experience and
expertise to make recommendations that deviate from the specific requirements of this framework. Deviating
from the framework may be justified where it will deliver additional efficiencies through improved mitigation of
environmental risks or cost savings. In such case, any deviation needs to:
comply with relevant national and jurisdictional guidelines, including the PFAS NEMP (HEPA, 2018);
provide assessments that are data-driven and evidence-based;
provide recommendations that allow for efficient and effective management options;
generally follow the principles within this framework, documenting any deviation; and
apply an appropriate risk tolerance.
Consultation with base environmental management staff and PFASIM Branch may be warranted depending
on the degree of risk in the project.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 14
Figure 1 Conceptual Site Model – Contamination Risks from PFAS (Defence Contamination Management Manual, GHD 2017)
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 15
3 SOIL
Manage soil (natural soil and fill materials in the form of rocks, excavation stone, and dried sediment) on a
work site in accordance with this Chapter.
3.1 Planning for risk management of PFAS contamination in soil
3.1.1 Consulting with other Defence decision-makers
Guidance on roles, responsibilities and stakeholders involved in decision-making for soil management is
provided in section 2.3. Consulting with stakeholders during the planning stage of works should assist with:
Identifying viable areas for soil reuse;
identifying the potential impact on Defence capability and Base redevelopment;
minimising volume of waste soil requiring management;
identifying opportunities for reuse in the works;
identifying reuse opportunity in other works (e.g. backfill material);
identifying material that is suitable for off-Base reuse or disposal;
avoiding works delays;
avoiding or minimising stockpiling (generally a temporary measure);
avoiding double-handling of waste material;
budgeting and cost-benefit analysis of soil management options;
identifying sampling and analysis requirements for soil characterisation, reuse or disposal; and
overlaying available data with project footprint to inform decision-making.
3.1.2 Soil sampling
The requirement for soil sampling should be carefully considered during the
project planning phase. If PFAS has been identified at the project site through
previous investigations (see section 2.2) or a site history review indicates legacy
activities that may have caused contamination, further sampling and analysis may
be required.
However, testing may not be required if a desktop review confirms that PFAS
contamination on the Base is considered unlikely. Refer to section 2.5 for sources
of soil data potentially relevant to the works site.
3.1.3 Managing very small volumes of contaminated soil
When the total volume of soil being managed for the project/works is less than 10 m3, it will usually be
appropriate and acceptable to reinstate the soil at the work site without testing. This is because responses to
PFAS contamination should be proportionate to the risk where disturbing small volumes of soil is unlikely to
have a material or measurable impact on the overall contamination on a Base. There are significant cost,
time and practicability limitations on testing in every scenario.
Areas of significant contamination, such as former Fire Training Areas, have been extensively investigated
and identified across the Defence estate. If work is being conducted within these areas as identified, the
volume threshold would not apply.
A reminder!
This framework is to be used for projects/work on the Defence estate.
It is not to be used for targeted PFAS investigations or remediation projects.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 16
When the works are adjacent to a water course, or an area potentially connected with groundwater, or are in
a hardstand area, consultation should be undertaken with the ESM on appropriate management options.
Where there is no reason to believe that soil is contaminated and it is not proposed to be disposed off-Base,
testing for PFAS is not required.
Examples where section 3.1.3 is likely to be applied includes footpath repairs, installing signposts or erosion
repairs. It does not apply where the aggregate of contaminated soil being managed by the works is greater
than 10 m3.
3.1.4 Management of sludge and slurry
Many works will generate soil sludge or slurry from construction and maintenance projects. De-water the
sludge or slurry and manage the separated sediment in accordance with this Chapter. Manage the
separated water in accordance with Chapter 4.
Non-destructive digging (NDD) technologies such as hydro-vac will mobilise PFAS from soils to water. For
larger projects in PFAS-contaminated areas, the planning phase should consider the value proposition of
NDD compared with dry methods.
3.2 Soil waste management hierarchy
This section provides the waste soil management hierarchy for soils that cannot be managed in accordance
with standard processes due to the presence of PFAS contamination:
1. on-work site management;
2. off-work site, on-Base management;
3. off-Base management; and
4. storage on-Base.
Excavation should be limited in order to limit the amount of soil that needs to be managed.
There is currently no Australian framework for remediating or treating PFAS contaminated soil. The PFAS
NEMP, Appendix C: Treatment Technologies Potentially Available in Australia provides a list of technologies
but does not take into consideration commercial viability or current feasibility.
Several treatment technologies are in the research and development phase with minimal commercially
available technologies currently suitable for remediation of PFAS in soils. Defence is working with other
Commonwealth agencies, states and territories to fund research programs to identify viable solutions. When
suitable treatment options become available, this guidance will be updated.
3.2.1 On-works site management
Reuse on the works site has the potential to give Defence the best environmental outcomes and most
efficient solution when managing PFAS contaminated soil.
Where reuse is proposed in areas where there are likely exposure pathways to potentially sensitive receptors
– ‘high-sensitivity’ locations (see section 3.2.42.4), the proposal should be subject to an assessment of
environmental risk, including the potential for bioaccumulation of PFAS in the receiving environment.
Dilution of PFAS contaminated soil is not an acceptable waste management strategy for creation of suitable
reuse material. In this context, the total mass, or ‘load’ of PFAS being added to the receiving environment is
also important, rather than their transient concentrations alone.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 17
3.2.2 Off-works site, on-Base management
Reuse of soil off the works site but on-Base may be considered where:
the volume of soil available to be reused cannot be utilised on the works site;
the engineering properties of the soil make it unsuitable for reuse on the works site; or
reuse on the receiving site will achieve a better environmental outcome than reuse on the works site.
These are only acceptable scenarios where reuse does not add to or increase the concentration of
contaminants, risk at the off-works site or otherwise increase the environmental risk at an uncontaminated
area on-Base, or lead to unacceptable risk.
The receiving site should be selected following an assessment of risk, including the consideration of a
conceptual site model for that site.
When Category 2 and 3 soils (see section 3.5) are applied to contaminated areas with appropriate mitigation
actions (on or off-works site) they are not to be treated as new contaminated sites within GEMS.
3.2.3 Off-Base management
Off-Base management includes treatment and/or disposal at a licensed waste facility, either within the State
or Territory or interstate.
Acceptance criteria and management options for PFAS contaminated soils vary between the States and
Territories. The waste classification and management guidance from the relevant state/territory
environmental regulator must be followed. The degree of guidance varies between jurisdictions and in some
cases a request will be considered by the approving agency on a case by case basis. Even if regulatory
approval is granted, not all landfill operators will accept PFAS contaminated waste.
Subject to State and Territory requirements (including transportation from or through different
states/territories), the option may exist for waste to be disposed of at a waste disposal facility within a
different state/territory.
3.2.4 Storage on-Base
On-Base storage is the least preferred option for managing excess contaminated soils.
Storage on-Base may include stockpiling or containment. Refer to Appendix C for stockpiling requirements.
The ongoing management requirements including financial considerations need to be assessed when
deciding on storage options for the long-term. Projects must cost ongoing maintenance for the life of the
stockpile and budget accordingly.
Suitability of location, material for storage and land availability should be determined through site-specific
assessment, noting that stockpiling is a temporary measure while awaiting determination of the appropriate
management action. Ongoing management of stockpiles, including monitoring, will need to be factored into
overall project costs.
If there is significant variability in contaminant concentrations, then the material should be appropriately
segregated and managed according to the concentrations of PFAS as categorised in section 3.5.
3.3 Reuse in high-sensitivity areas
Reuse of PFAS contaminated soils in the following scenarios should normally be avoided and must be
assessed to demonstrate that the environmental and human health risks are acceptable. This will include
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 18
consultation with all relevant stakeholders. This assessment of direct and indirect risk is required if the soil is
to be applied or used:
on land used for agricultural or aquaculture purposes ;
as fill in residential developments;
as compost, fertilisers or soil conditioners;
as fill or burial within 2.0 metres of the seasonal maximum groundwater level;
as fill or burial or reuse in locations potentially affected by reasonably foreseeable future rises in
groundwater or near stormwater drains;
within 200 metres of a wetland area or surface water body (e.g. river, pond);
in areas prone to flooding and with reactive soils; and
where contaminated soil, sediment or water can enter areas of national environmental significance
protected under the EPBC Act 1999, and areas of environmental significance as identified by the
relevant State/Territory.
Some Bases are highly constrained due to flooding, proximity to water or elevated groundwater. In these
cases reuse options may consider coordination with future planned remediation activities, such as through
infrastructure work, PFAS Management Area Plans or other Base works where treatment or management of
soil may be required.
3.4 Soil sampling and characterisation
Soils to be disturbed by works are to be sampled in accordance with this section, unless:
the soil has previously been sampled for PFAS; or
preliminary investigation or desktop analysis has determined that it is not likely for PFAS
contamination to be present at the Base.
The ESM/ESO should be satisfied that sufficient data are available to apply this management guidance.
In-situ sampling is preferred, but where this is not feasible, ex-situ sampling for classification of excavated
materials will be required.
Samples are to be collected by a suitably qualified and experienced environmental professional.
3.4.1 Approaches to Sampling
Due to the nature of legacy AFFF use in training and incident response, and the known characteristics of
PFAS fate and transport, the impact of PFAS contamination is generally less localised and more widespread
than for other contaminants. Australian Standard AS 4482.1 (2005) provides guidance on the number of
samples per area needed to detect a hot spot of a given diameter on a contaminated site with sufficient
confidence.
State and territory guidance is also available on the number of samples per volume needed to characterise
excavated material. These approaches are suitable for sampling at a site not previously assessed. However,
where sampling has already been conducted, it may be possible to use a site specific conceptual site model
(CSM) to develop an estimated characterisation for soils to be disturbed. In these cases, significantly fewer
samples would need to be collected in order to confirm the characterisation. Sampling plans to fill any data
gaps prior to the development of management options for excess soils should ensure that the density of
sampling is appropriate.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 19
3.4.2 Soil sampling - disposal off Base
Sampling requirements for the purposes of off-site landfill disposal should be undertaken in accordance with
the PFAS NEMP and specific State and Territory guidance, and may require other contaminants of concern
to be analysed. Engagement with the State and Territory regulator will be required.
3.4.3 Soil sampling - reuse on Base
Any reuse on Base must be agreed following consultation with the Base ADES/ESM and other relevant
stakeholders (see 2.3 and 3.1.1)
To evaluate on-Base reuse/management options, samples are to be analysed for the following:
PFAS analysis that includes the standard laboratory suite as per Appendix B with laboratory
reporting limits of 0.005 mg/kg (5 µg/kg).
Other identified contaminants of potential concern based on identification through a preliminary
conceptual site model. This may include reference documentation such as desktop studies, PSI or
DSI if available.
To assist with decision making for the reuse location, leachability testing using the Australian Standard
Leaching Procedure (ASLP5) may be applied to select samples of the material to be reused and the reuse
location to compare the leachability and validate that the reuse proposal will not increase risks of PFAS
migration or otherwise result in an unacceptable risk.
3.5 Soil categorisation
Soils disturbed during construction or maintenance work will fall into one of four categories, where Category
1 is the highest concern:
Table 2 Soil Categories
Category 1 Excavated soils with
PFOS + PFHxS
concentrations of 20
mg/kg6 or more.
Unacceptable risk destroy
Category 1 soil is to be excavated and treated or temporarily stockpiled for
later treatment in accordance with the PFAS Engineered Stockpile Facility
Performance Specification. The stockpile should be designed for whole of
life cycle and constructed to limit infiltration of precipitation, surface water
and groundwater into the PFAS contaminated materials.
Category 2 Excavated soils with
PFOS + PFHxS
concentrations less than
20 mg/kg but greater
than 1 mg/kg7.
High risk contain and manage
Category 2 soil can be reused within the works site provided that exposure
to receptors, and water more generally is minimised. If reuse is not
appropriate on the works site, then an assessment of risk should be
undertaken to evaluate the following options: off-base disposal to landfill, or
on-base encapsulation, containment, treatment and/or destruction.
Mitigation will be required if receptors are potentially to be exposed to
contaminants.
5 Deionised water
6 Human health criterion for direct soil contact for industrial land use, PFAS NEMP
7 Human health criterion for direct soil contact for public open space, PFAS NEMP
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 20
Category 3 Excavated soils with
PFOS + PFHxS
concentrations less than
1 mg/kg but greater
than 0.01 mg/kg8.
Moderate risk reuse with assessment and mitigation
Category 3 soil can be reused within the works site with no additional
mitigation procedures or on-Base (subject to Base approvals) if the risk to
human health or the environment is not increased or otherwise results in
unacceptable risk. Some mitigation may be required if potential pathways
exist and there are potential high sensitivity receptors.
Category 4 Excavated soils with
PFOS + PFHxS
concentrations less than
0.01 mg/kg.
Acceptable risk reuse on site or on base without assessment or
mitigation unless a previous site assessment suggests otherwise.
Extensive testing for PFAS on the Defence estate has not identified PFOA as a limiting factor for decision
making. Categorisation of soil are usually determined by PFOS and PFHxS concentrations, as relevant
guidelines for PFOA are significantly higher than PFOS and the frequency and levels of PFOA detected are
less than combined PFHxS and PFOS.
3.6 Soil management actions
The following soil management actions are outlined in accordance with the soil categories detailed in
section 3.5. These actions only apply to soils that cannot be managed as per standard practice due to the
presence of PFAS contamination.
3.6.1 Category 1 soil management
Category 1 soils are to be excavated and treated or temporarily placed in a lined and covered stockpile on-
Base at a location authorised by a Defence environmental officer (ADES/ESM/ESO) following consultation
with work teams (see section 2.3). Management actions are provided in Table 3.
PFASIM Branch is to be notified when Category 1 soils are encountered. The PMAP for the Base may have
identified a preferred management approach for the contamination. Where practicable double-handling
should be avoided through aligning the excavation with the treatment.
Table 3 Category 1 soil management actions
Category 1 Trigger levels Management actions
Soil - Human Health –Property
Users Commercial / Industrial
Setting
PFOS + PFHxS > 20 mg/kg
Soils with PFOS + PFHxS of 20 mg/kg or more must be excavated and treated or
temporarily stockpiled for later treatment with like materials according to Defence
policy. The design of the stockpile cell must prevent leaching. Refer to the PFAS
Engineered Stockpile Specification.
PFOS, PFOA, or PFHxS >50
mg/kg
The reuse of PFAS contaminated material above the Stockholm Convention low
content limit of 50 mg/kg will not be considered.
3.6.2 Category 2 soil management
Category 2 soils may be reused within the works site with appropriate mitigation strategies (Table 4),
provided that reuse does not increase the cumulative risk profile at the site, or create new pathways to
8 Interim soil – ecological indirect exposure for all land uses, PFAS NEMP
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 21
sensitive environmental receptors (including impacted soil runoff into waterways and migration of leached
PFAS into surface waterways or groundwater).
The reuse location should be authorised by a Defence environmental officer (ADES/ESM/ESO) following
consultation with work teams (see section 2.3).
If the works site is unable to feasibly reuse this material (e.g. excess to work needs, geotechnical
unsuitability), it may be disposed off-Base, reused elsewhere on-Base with risk mitigation, or managed as
per Category 1 soils. If stabilisation is the method chosen to mitigate risk, then leachability testing should be
used to validate the success of the risk mitigation. Stabilised soils should not be placed in an environmentally
dynamic area (such as flood prone areas).
On-Base reuse will require risk mitigation measures such as capping or stabilisation and will be dependent
upon the site setting. These measures should be selected following consideration of a Conceptual Site
Model (CSM) to identify both receptors and exposure pathways and with the authorisation of a Defence
environmental officer (ADES/ESM/ESO) following consultation with work teams. Reuse must not increase
the level of environmental risk posed by PFAS impacted materials in their current pre-work state or at the
proposed reuse location.
Table 4 Category 2 soil management actions
Category 2 Trigger levels Management actions
PFOS + PFHxS
1.0 mg/kg to < 20 mg/kg
Exceedance of the Category 2 trigger level does not preclude reuse of these
materials on the site. Re-use would require careful consideration and assessment of
risk.
Reuse elsewhere on base will likely require mitigation strategies or any other
additional measures to prevent new exposure pathways or an increase in risk to
environmental or human health.
Off-base disposal is permitted subject to the requirements of the jurisdictional
regulator. Pre-treatment may be required.
3.6.3 Category 3 soil management
Category 3 soils can be reused on the works site without further treatment or management or on-Base at
locations authorised by a Defence environmental officer (ADES, ESM, ESO) following consultation with
works teams (see section 2.3) and an assessment of risk.
The assessment of risk should be undertaken to confirm that there is no increased risk, or unacceptable risk,
to human health or sensitive environmental receptors as a result of the re-use. The assessment should have
regard to the total mass loading at the re-use location and the likely mass flux arising from the re-use. This
will require a practical and evidence-based approach and may include a review of existing conditions,
development of a conceptual site model and an evaluation of the change in relative risk.
Leachability testing may assist as one line of evidence to develop an understanding of the likely change in
risk and may be used to compare the proposed re-use with the baseline scenario at the proposed re-use
location. The total and leachable concentration of PFAS in the re-use materials should be lower than those
at the proposed re-use location.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 22
Table 5 Category 3 soil management actions
Category 3 Trigger Level Management actions
PFOS + PFHxS
0.01 to < 1.0 mg/kg
No additional mitigation is required for work-site re-use. An assessment of risk
should be conducted prior to re-use elsewhere on base.
If it cannot be determined whether the risk profile of the receiving area will be
impacted by the reuse, the management actions for soils will be the same as for
Category 2 (see section 3.6.2).
Off-Base disposal is permitted subject to the requirements of the jurisdictional
regulator.
3.6.4 Category 4 soil management
Soils less than 0.01 mg/kg9 are available for reuse on the works site or on-Base, without further treatment or
management, subject to appropriate Defence approvals. This includes agreement with the BM or their
representative on the works team, or where other considerations indicate that additional management may
be required, such as where sensitive environmental receptors are present.
This is considered protective of the most sensitive exposure pathways for any land management actions.
Table 6 Category 4 soil management actions
Category 4 Trigger Level Management actions
PFOS + PFHxS
< 0.01 mg/kg
Available for reuse on the works site or on-Base, without further assessment or
mitigation actions.
This will be subject to Defence approval, such as agreement with the BM or their
representative on the works team, or where other considerations indicate that
additional management may be required, such as where sensitive environmental
receptors are present.
Off-Base disposal is permitted subject to the requirements of the jurisdictional
regulator.
9 This soil is considered protective of indirect exposure to secondary consumers, as the most sensitive exposure pathway for any land management actions.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 23
4 WATER
Manage water on a work site in accordance with this Chapter.
This guidance applies to water generated or encountered during construction works processes or dewatering
actions, including runoff, surface water drainage, groundwater and stormwater.
It does not cover waste water from industrial processes or waste treatment plants nor process waste. Refer
to the Defence Pollution Prevention Management Manual.
4.1 Planning for risk management of PFAS contamination in water
4.1.1 Water management principles
Water is the primary pathway for PFAS contamination from its source to people and other receptors. This
means that managing contaminated water during works is critical to ensuring that exposure risks (new or
increased) are not realised.
Water management on a works site should conform to:
the Defence Estate Water Policy 2014; and
the Defence Estate Water Strategy 2014-2019.
The following principles apply to the management of all water on or from works:
the choice of management action should not measurably increase contamination in the receiving
environment or lead to an unacceptable risk;
the assessment of risk should account for the potential for bioaccumulation of PFAS in the receiving
environment;
in ecologically sensitive areas, a local catchment assessment may be required to demonstrate that
the overall PFAS load within the catchment will not be materially increased; and
the choice of management action must comply with applicable State or Territory legislation with any
required licences or permits to be obtained, for example regulators may require management
actions that measurably decrease PFAS concentrations or loads in the receiving environment.
A conceptual site model, along with site specific hydrology and hydrogeology needs to be considered when
determining the impact of water reuse within the work site, the Base or the broader environment. The
assessment should include:
an understanding of potential migration pathways;
an understanding of environmental values which may be impacted by change in surface water and
groundwater quality.
presence of sensitive on and off-site receptors;
seasonal fluctuations in surface and groundwater;
site drainage;
aquifer/groundwater characteristics; and
surface water / groundwater interactions.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 24
4.1.2 Prevention of stormwater contamination
Stormwater is surface water that originates from rain. Stormwater can take up PFAS from contaminated
materials such as soil, concrete and asphalt.
To avoid this, stormwater should be diverted around site excavations, to the extent possible, and managed in
line with relevant stormwater practices for the Base. This will limit the volume of water required to be
managed for the works.
4.1.3 Managing very small volumes of contaminated water
When the total volume of water being managed for the works is <1000 L, water should be infiltrated near to
the work site or in consultation with the ESM/ESO to another adjacent area. This exemption only applies
when the water is removed from and returned to the environment in the same location and at the same time.
Where the contamination levels are known and the addition of <1000 L of water would not measurably
change the characteristics at the infiltration location, testing for PFAS is not required (see section 1.2.2).
4.2 Sampling and analysis
Where water samples are to be collected and analysed for PFAS, the below guidance should be followed.
It is important to obtain samples that represent PFAS concentrations in the water from which they are
collected. Conventional sample handling and processing practices can generally be applied for PFAS in
water samples, with particular care to be taken to avoid cross contamination. Samples are to be collected by
a suitably qualified and experienced environmental professional. Laboratory analysis should be conducted
according to the NEPM (2013) and the PFAS NEMP (HEPA 2019). The standard laboratory suite for PFAS
analysis is provided in Appendix B.
Some considerations include:
selecting appropriate sampling equipment;
obtaining a representative sample or samples; and
appropriate labelling, preserving, storing and transporting of samples for analysis.
4.2.1 Project coordination
Sampling of monitoring wells and some surface water locations will typically be coordinated by other programs such as:
Ongoing Monitoring Plans (OMP) or Remedial Action Plans (RAP) under the PMAPs;
the Regional Contamination Investigation Program (RCIP) delivered through the Directorate of Contamination Assessment, Remediation and Management (DCARM);
the Water Quality Monitoring Program (WQMP) delivered by the Directorate of Estate Energy & Environment Service Delivery (DEEESD).
Data from these programs can be used to inform project planning decisions regarding water management. This includes confirmation of other monitoring activities being undertaken, to avoid duplication of effort and other issues, such as an impact on data integrity (e.g. if a well has been accessed and purged recently by another program).
Additionally, review current and future scope for water treatment plants (WTP) across the Base with all relevant stakeholders. Where possible, coordinate scoping requirements to avoid duplication of capital and operating costs and reduce any program delays. It is critical in the management of aquifers and other water bodies which may be impacted by discharge, extraction or reinjection of water.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 25
4.2.2 Other PFAS compounds
Sometimes there are cases where PFOS, PFOA and PFHxS concentrations in water being assessed for
reuse are below LOR but other PFAS compounds in the Standard Laboratory Suite (Appendix B) such as
PFBA, 6:2 FTS, 8:2 FTS, PFPeA, PFHxA are reported.
The PFAS NEMP advises that management decisions can be made with PFOS, PFHxS, and PFOA in
relation to the guideline values10. Other PFAS contaminants may affect the certainty with which
management decisions can be made. If high concentrations of other PFAS are present, then a more
conservative assessment may be warranted and consultation should be undertaken with PFASIM Branch.
4.3 Water management
Water management decisions should consider whether discharge of water may change the risk to the
environment or human health. This includes any potential measurable difference to PFAS concentrations in
the receiving environment, including surface water, groundwater, soils or biota if discharge was to occur
through release of non-treated water. Depending on site specific circumstances, regulators may also require
treatment prior to discharge.
Discharge of extracted water may be carried out, subject to State or Territory regulations, in order of
preference within the risk assessment process:
Irrigation or infiltration on-works site.
Irrigation or infiltration off-works site but on-Base.
Discharge to creeks or storm water drains (on-Base or off-Base).
Irrigation refers to the controlled supply of water for dust suppression, maintenance of playing fields or
watering of other vegetation (gardens, bushes, trees).
Infiltration refers to the process by which water on the ground surface enters the soil. The infiltration rate
decreases as the soil becomes saturated. If the application rate exceeds the infiltration rate, runoff will
usually occur unless there is some physical barrier.
All discharges of water that may impact on soils, surface water or groundwater require a risk-based
assessment that considers:
concentration of PFAS contamination;
volume of water to be returned to the groundwater system;
existing groundwater conditions or aquifer properties;
profile (type, concentration) of other contaminants in the water to be discharged relative to the
existing groundwater conditions;
potential sensitive receptors including aquatic ecosystems and direct contact through recreational
water use; and
regulatory requirements
Where the assessment of risk concludes that there is an unacceptable risk, water may need to be treated to
acceptable levels prior to discharge or disposal.
10 Published literature could inform management decisions, or State/Territory specific polices.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 26
4.3.1 Irrigation and Infiltration
Irrigation and infiltration should be located within the work area or as close as practicable to the extraction
location, although irrigation may in some circumstances take place on the wider Base (sports field
maintenance, garden irrigation). Such discharges must be agreed with the ADES/ESM/ESO in advance.
Conduct irrigation in a controlled manner to prevent:
Contamination of non-contaminated areas;
irrigation run-off beyond the irrigation area;
the creation of hydraulic gradients that could result in migration of impacted groundwater into
surface water bodies; and
run-off of irrigation water back to its origin or otherwise creating a water ‘loop’ that may mobilise
additional PFAS contamination from soils, unless the loop is part of a treatment system.
Irrigation and infiltration of large volumes of water should be confirmed by an environmental consultant in
consultation with a Defence environmental officer once the dewatering volumes and site conditions have
been assessed. Suitable storage capacity must be provided to allow controlled irrigation, including
consideration of precipitation affecting volumes if stored in an open manner, such as holding dams or
evaporation ponds. Management measures depend on the volume of extracted water to be irrigated, as
provided in Table 7. Refer to the work objectives and application of this framework and source all available
data to use professional judgement in making an assessment of risk.
Decision paths for water discharge are provided in Flowchart 1.
Table 7 Management of Extracted Water
Total volume Irrigation and Infiltration Management Measures
1,000 – 100,000 L If the PFAS contamination levels of the discharged water are less than or equal to
contamination levels in the groundwater and there is no change to the risk profile or
cumulative environmental impact caused by discharge, and no unacceptable risk,
then no treatment is required and water can be used for irrigation and infiltration.
> 100,000 L The proposed discharge by irrigation/infiltration should not result in an increased
ecological risk, as determined through consultation and assessment of risk by a
suitably qualified environmental consultant. This must include an assessment of
groundwater-surface water interactions.
Where drinking water is known to be a beneficial use for groundwater in the vicinity
of the Base, an environmental consultant should confirm whether there is a pathway
to the drinking water source and assess the risk to sensitive receptors.
Treatment of water may be required to mitigate the risks.
4.3.2 Discharge via creeks or stormwater drains
Discharge of contaminated water via creeks or stormwater drains is likely to directly result in an exposure
pathway to potential human health or ecological receptors. Therefore, conservatism in decision making
should apply.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 27
Discharge via creeks or stormwater drains may only take place:
where PFAS concentrations are less than the NEMP screening criteria; and
in accordance with relevant state/territory laws and local water authorities including holding any
required licences and permits; or
In accordance in a negotiated agreement with the jurisdictional regulator.
If treated, water discharged to drainage or surface water should be treated to the NEMP screening criteria or
< LOR11. This applies in the context of treated water taken from the environment to another area arising from
construction and maintenance and projects only.
11 Reference Table 5 of the Draft PFAS NEMP 2.0 (2019: 31). As noted, a ‘detect’ threshold may be applied rather than a quantified measurement, given the 99% species protection
level for PFOS are close to the level of detection.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 28
Flowchart 1 - Treatment options for irrigation and infiltration
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 29
5 CONSTRUCTION AND DEMOLITION WASTE
5.1 Construction and Demolition waste – management principles
For the purposes of this guidance, Construction and Demolition (C&D) waste refers to materials of the built
or natural environment that is neither ‘soil’ (see Chapter 3) nor ‘water’ (see Chapter 4). It includes materials
that are commonly recycled such as concrete, bricks, asphalt, tiles and metals, materials that are commonly
reused or reprocessed such as green waste, trees and boulders, and materials that are commonly disposed
to landfill such as timber, cladding, fittings and fixtures.
Currently in Australia there is insufficient regulatory guidance on management options for PFAS
contaminated C&D waste. This chapter has been prepared in the interim to bridge this gap in regulatory
guidance.
This chapter is subject to and must be read in the context of all other Defence guidance and policy on C&D
waste and nothing in this chapter provides authority to deviate from standard Defence policy. This includes
but is not limited to:
Department of Defence Pollution Prevention Management Manual
Department of Defence Contamination Management Manual
5.2 Lessons from previous investigations
The extent to which construction materials, plant and equipment may become contaminated will depend on
several factors including:
Contact with PFAS impacted soil or groundwater, for example a building slab located in a PFAS
impacted area is more likely to be PFAS impacted than the building walls sitting on the slab.
Similarly, pipes carrying PFAS contaminated water may become PFAS impacted, even if the pipes
themselves run through an otherwise PFAS free location.
The type of material and its porosity will influence the ability and rate at which PFAS contamination
in surrounding soil or water can absorb into the material. For example, asphalt and concrete are
known to more easily adsorb PFAS than steel.
Exposure concentration, the higher the concentration of PFAS in surrounding soil or water, the
higher the potential concentration of PFAS absorbed into the construction materials, particularly if
exposure has occurred over a long period of time.
Exposure duration, the longer the construction materials, plant and equipment have been in
contact with PFAS contaminated soil or water the more PFAS can be absorbed.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 30
Defence has commissioned a significant amount of testing for PFAS in the natural and built environment.
The following points and observations within Table 8 provide important context for this chapter:
Table 8 Observations of PFAS contamination likelihood
LIKELY to be contaminated by PFAS –
warrants environmental testing
NOT likely to be contaminated by PFAS –
does not warrant environmental testing
Building materials in direct contact with AFFF
concentrate; the application of AFFF foams; trade
waste treatment plants, or sewage treatment plants.
Porous building materials in contact with elevated
concentrations of PFAS. Typical building materials
that are considered porous include: masonry,
concrete, and timber.
Vegetation on or immediately adjacent to fire training
areas.
Tanks and pipes used for AFFF concentrate, fire
training wastewater, trade waste or sewage treatment
plants.
Concrete or asphalt pavement used for routine AFFF
training.
Areas where AFFF was used for incident response.
Building materials in contact with environmental
concentrations of PFAS (< 1 mg/kg in soils or < 10
µg/L in waters).
Non-porous construction materials, typically including:
metal and plastic objects (e.g. steel/plastic fencing,
pipes, and sheet piles), plant and equipment (e.g.
water tanks, plastic or metal pipes, pumps, water
carts, mobile plant and equipment).
Vegetation in areas not adjacent to fire training areas
or that did not receive applications of AFFF foam.
Other tanks and pipes.
Other concrete or asphalt roads and pavements.
Car parks.
5.3 Whether to conduct sampling of C&D waste
5.3.1 Sampling requirements
Refer to Flowchart 2 for determination of sampling requirements of C&D waste. Where sampling of C&D
waste is required:
the PFAS suite must include the standard laboratory suite as per Appendix B with standard
laboratory reporting limits (0.005 mg/kg ,5 µg/kg), subject to matrix interference; and
the analysis must include other identified contaminants of potential concern.
Samples should be taken from both the material estimated to be the most highly contaminated, and material
likely to be representative of the bulk of the area to be removed in order to determine a conservative
estimate of the concentration of PFAS within the material
If there is significant variability of contamination levels, material with differing levels should be segregated
and managed according to the contamination levels. This will allow more efficient management of waste by
avoiding contaminating large volumes of low contaminated waste by mixing with smaller volumes of highly
contaminated waste.
5.3.2 Disposal to commercial landfill
If the C&D waste is to be disposed to a commercial landfill, it must be classified in accordance with standard
practice and the waste regulations for the relevant jurisdiction. If this process does not require testing for
PFAS and the source of the C&D waste is listed in the right hand column of Table 8 above, then the C&D
waste should not be tested for PFAS.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 31
Where landfill disposal is to be considered, Toxicity Characteristics Leaching Procedure (TCLP), Australian
Standard Leaching Procedure (ASLP) tests or Total Oxidisable Precursor Assay (TOPA) may be required by
the jurisdictional regulator. Confirm the specific requirements with the landfill operator and the regulator.
5.4 Reuse of C&D waste
C&D waste should only be reused on the Defence estate where that use is beneficial and in accordance with
relevant guidelines and policies. If the material would not normally be reused, then the presence or absence
of PFAS contamination should not alter that.
Analysis and beneficial reuse of C&D waste should ensure that the receiving environment has the same or
higher risk profile and new potential pathways to sensitive environmental receptors are not created. Reuse
should not increase the level of environmental risk posed by PFAS impacted materials in their current pre-
work state.
There is not enough scientific literature or regulatory guidance available to provide definitive criteria for
management options on C&D waste. The soil criteria should not be used in the absence of guidance values.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 32
Flowchart 2 – Sampling considerations for C&D waste
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 33
APPENDIX A: GLOSSARY
ADES Assistant Director Environment and Sustainability
AFFF Aqueous film forming foam
Attenuation In this context, attenuation refer to dilution and absorption without the breakdown (Ref
Flowchart 1).
Base In this document, a reference to ‘Base’ also includes a reference to other properties on the
Defence Estate.
BM Base Manager
BSC Base Services Contract
C&D waste Materials that are not defined as soil or water. Includes concrete, bricks, asphalt, and metals.
It does not include rocks and excavation stone
CFI Defence Capital Facilities and Infrastructure Branch
CSM A Conceptual Site Model identifies the source of the contaminants, where are they currently
found, any biological or geochemical transformations, and where they eventually end up. This
information is used to identify the potential risks to human health and ecosystems
Cumulative
Environmental Impact
Cumulative environmental impacts result from different actions that would not normally be
accounted for collectively but may, when considered together, cause risk to the environment
through accumulation.
Risk management actions should account for cumulative exposure that may heighten
potential impact to the receiving environment.
DCARM Directorate of Contamination Assessment, Remediation and Management
EMOS Estate Maintenance and Operational Services
ESM Defence Environment and Sustainability Manager
ESO Defence Environment and Sustainability Officer
GEMS EFM-CSR Garrison Estate Management System, Environmental Factor Management - Contaminated
Sites Records
DSI Detailed site investigation
ECC Environmental Clearance Certificate
EEB Defence Environment and Engineering Branch
ERA Ecological Risk Assessment
EPA Environment Protection Authority – generally a state/territory environmental regulator
EPBC Act Environment Protection and Biodiversity Conservation Act, 1999
Exposure pathway The means by which hazardous substances move through the environment from a source to
a point of contact with a receptor (such as a person)
FEQG Federal Environmental Quality Guideline (Canada)
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 34
FSANZ Food Standards Australia New Zealand
GAC Granular activated carbon
HBGV Health Based Guidance Values
HHERA Human Health and Ecological Risk Assessment
HHRA Human Health Risk Assessment
Infiltration The process by which water on the ground surface enters the soil
IRM Interim Response Management
LOR Limit of reporting
NEMP The PFAS National Environmental Management Plan (January 2018)
NEPM National Environment Protection (Assessment of Site Contamination) Measure 2013
OMP Ongoing Monitoring Plan (for PFAS, under the PMAP)
PDS Project Delivery Services
PFAS Per- and Poly-fluoroalkyl Substances. The principal compounds, and those being managed
by this Framework, are PFOS, PFOA and PFHxS
PFASIM Branch Defence PFAS Investigation & Management Branch
PFHxS Perfluorohexane sulfonate
PFOA Perfluorooctanoic acid
PFOS Perfluorooctane sulfonate
PMAP PFAS Management Area Plan
PMCA Project Management Contract Administrator
ppm Parts per million (mg/kg or mg/L)
ppb Parts per billion (µg/kg, µg/L, or ng/mL)
PSI Preliminary Site Investigation
RAP Remediation Action Plan
RCIP Regional Contamination Investigation Program
Receptor Who or what can be affected by pollution
Sensitive receptor People or other organisms that can be adversely impacted by exposure to pollution or
contamination because of increased sensitivity or increased exposure
SDD Defence Service Delivery Division
SME Subject Matter Expert
Source A source can be primary or secondary. Primary sources are generally areas where AFFF was
used or stored, secondary sources may be an accumulation of contamination in the
environment that causing secondary effects.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 35
TCLP Toxicity Characteristic Leaching Procedure
TOPA Total Oxidisable Precursor Assay
Works site The defined area for carrying out specific works.
WQMP Water Quality Monitoring Plan
WTP Water treatment plant
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 36
APPENDIX B: STANDARD LABORATORY SUITE
CORRECT AS AT 21 DECEMBER 2018
Group Acronym Chemical Compound CAS No
Pe
rflu
oro
alk
an
e
Su
lfo
nic
Acid
s
PFBS Perfluorobutane sulfonic acid 375-73-5
PFPeS Perfluoropentane sulfonic acid 2706-91-4
PFHxS Perfluorohexane sulfonic acid 355-46-4
PFHpS Perfluoroheptane sulfonic acid 375-92-8
PFOS Perfluorooctane sulfonic acid 1763-23-1
PFDS Perfluorodecane sulfonic acid 335-77-3
Pe
rflu
oro
alk
an
e
Carb
ox
yli
c A
cid
s
PFBA Perfluorobutanoic acid 375-22-4
PFPeA Perfluoropentanoic acid 2706-90-3
PFHxA Perfluorohexanoic acid 307-24-4
PFHpA Perfluoroheptanoic acid 375-85-9
PFOA Perfluorooctanoic acid 335-67-1
PFNA Perfluorononanoic acid 375-95-1
PFDA Perfluorodecanoic acid 335-76-2
PFUnDA Perfluoroundecanoic acid 2058-94-8
PFDoDA Perfluorododecanoic acid 307-55-1
PFTrDA Perfluorotridecanoic acid 72629-94-8
PFTeDA Perfluorotetradecanoic acid 376-06-7
Pe
rflu
oro
alk
yl
Su
lfo
na
mid
es
FOSA Perfluorooctane sulfonamide 754-91-6
MeFOSA N-Methyl perfluorooctane sulfonamide 31506-32-8
EtFOSA N-Ethyl perfluorooctane sulfonamide 4151-50-2
MeFOSE N-methyl perfluorooctane sulfonamidoethanol 24448-09-7
EtFOSE N-Ethyl perfluorooctane sulfonamidoethanol 1691-99-2
MeFOSAA N-methyl perfluorooctane sulfonamidoacetic acid 2355-31-9
EtFOSAA N-ethyl perfluorooctane sulfonamidoacetic acid 2991-50-6
(n:2
) F
luo
rote
lom
er
Su
lfo
nic
Acid
s 4:2 FTS 4:2 Fluorotelomer sulfonic acid 757124-72-4
6:2 FTS 6:2 Fluorotelomer sulfonic acid 27619-97-2
8:2 FTS 8:2 Fluorotelomer sulfonic acid 39108-34-4
10:2 FTS 10:2 Fluorotelomer sulfonic acid 120226-60-0
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 37
The standard PFAS Suite is based on consideration of:
US EPA Method 537.1 (November 2018). Determination of Selected Per- and Polyfluorinated Alkyl
Substances in Drinking Water by Solid Phase Extraction and Liquid Chromatography/Tandem Mass
Spectrometry (LC/MS/MS), Publication EPA/600/R-18/352 Version 1.0.
US EPA Method 821 (December 2011). Draft Procedure for Analysis of Perfluorinated Carboxylic
Acids and Sulfonic Acids in Sewage Sludge and Biosolids by HPLC/MS/MS, Publication EPA-821-R-
11-007.
Western Australia Department of Environment Regulation (WA DER; January 2017). Interim
Guideline on the Assessment & Management of Perfluoroalkyl & Polyfluoroalkyl Substances WA
DER, US EPA Method 537 and US EPA Method 821.
Table B15 of US DoD/DoE QSM 5.2.
Current capabilities of analytical laboratories in Australia.
The laboratory is required to use NATA accredited methods based on NEPM, US EPA, Table B15 of US
Department of Defence/Department of Energy (US DoD/DoE) Quality Systems Manual 5.2 (QSM) and
American Society for Testing and Materials (ASTM) methods as appropriate.
The laboratory shall undertake all PFAS analysis in accordance with Table B15 of US DoD/DoE QSM 5.2
and US EPA Method 821. Where the laboratory is currently using a method not in accordance with Table
B15 of US DoD/DoE QSM 5.2 or USEPA 821 it should specify the methodology used, variation from Table
B15 of US DoD/DoE QSM 5.2 or USEPA 821 and capacity to modify current methods in accordance with
Table B15 of US DoD/DoE QSM 5.2 or USEPA 821.
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 38
APPENDIX C: STOCKPILING REQUIREMENTS
The purpose of this Appendix is to provide guidance where a decision has been made to stockpile
contaminated soil pending future management. Additional, more detailed guidance is provided in the Draft
PFAS NEMP 2.0 (HEPA 2019) Management options should be assessed using all available data and in
accordance with the soil waste management hierarchy prior to deciding on stockpiling.
Mandatory requirements for stockpiles
Annex C of the Defence Contamination Management Manual - Soil Stockpiles and Reuse of Excavated
Material includes the following mandatory stockpiling requirements:
Stockpiling of excavated soil is to be used as a short-term (or temporary) management measure for
a period no greater than 12 months.
If a stockpile is to be retained for a duration of greater than 12 months, Site Selection Board
approval is required.
A Stockpile Register must be maintained by Service Delivery Division personnel or Base Service
Contractors to capture the location, origin, composition, volume and responsibility (ownership) for all
stockpiles that are expected to remain at the Base for greater than 12 months.
During the design phase prior to construction, contractors should review options to minimise the
amount of soil to be managed and to consider options for reuse of the excavated soil.
Consult with the ESM and the project/works team to agree a suitable end point of excavated
material.
Identifying a suitable end point for stockpiled soil early in design and delivery of all capital works projects is
the responsibility of the contractor and the Defence Project Manager. If there is demonstrated evidence that
no reuse opportunities exist on the base, then other options (see Annex C of the Defence Contamination
Management Manual) should be pursued and funded by the project.
In situ pre-characterisation of soils is encouraged to provide information prior to excavation that should
inform soil management options. Soil which is found to be Category 3 or 4 should be considered for reuse
prior to consideration of stockpiling. Category 1 soil must be temporarily stockpiled for later treatment.
All stockpiles are considered temporary and any maintenance of temporary stockpiles until such time as they
are reused or disposed off-site must be negotiated through proper handover takeover processes with the
Zone.
Stockpile location
The mobilisation of PFAS mainly occurs when PFAS contaminated soil (and other contaminated material)
comes into contact with water. Stockpiled material should be kept as dry as possible to minimise the risk of
contamination in the stockpile creating additional sources or contaminant load. This may be achieved by:
selecting suitable locations;
incorporating suitable designs;
employing effective work procedures; and
stormwater management.
Stockpile locations should be agreed with the BM or their representative prior to commencement of
excavation works. When selecting potential sites the following should be taken into consideration:
DEFENCE PFAS CONSTRUCTION AND MAINTENANCE FRAMEWORK
Version 2.1 – July 2019 BS1062257 39
proximity to potential pathways (drainage channels, waterways, surface water and groundwater flow)
and sensitive receptors (see section 3.2.4);
contaminant levels in soil and groundwater at the stockpile site;
site topography;
proximity to excavation site, related haulage costs and impact on Base traffic/operations;
maintaining availability of land for future development and capability; and
availability of land to expand the stockpile if additional capacity is required in the future
Stockpile design
Where stockpiling of Category 2, 3 or 4 contaminated soils is required for a period up to twelve months
appropriate risk-based measures should be used giving consideration to the nature of the materials and the
surrounding environment. This will normally include protecting the stockpile from rain and from overland
stormwater flow.
A stockpile should have low permeability to reduce the risk of PFAS leaching into the environment. Soils to
be contained would have typical average PFAS concentrations up to 10 mg/kg. Provided the stockpiled
material is sufficiently dry and the capping or barrier system is waterproof, then it does not matter whether
the liner is PFAS-resistant. The objective is to stop water from moving, not PFAS. This is in contrast to other
barrier containment projects, such as landfills, remediation or containment of high level contaminants that
are solvents and have the ability to dissolve the liner.
Where stockpiling Category 1 soil for any time period, an engineered stockpile is required. Refer to the
Defence PFAS Engineered Stockpile Facility Performance Specification. Performance based specifications
may be adopted to support designing a stockpile to meet local conditions such as:
volume and type of spoil (e.g. sandy/clay based soil, concrete, bitumen);
available footprint of land;
level of the water table;
local environmental sensitivities;
proximity to flood plains, drainage channels and waterways;
proximity to airfields or critical other infrastructure; and
annual weather conditions and expected severe weather events.